Reasonable reunification efforts; Accommodations; Child’s best interests

Concluding that: (1) the trial court did not err by finding that the DHHS made reasonable efforts toward reunification, and (2) termination of respondent-father’s parental rights was not in the child’s (MSS) best interests, the court affirmed. He claimed the “DHHS did not provide reasonable accommodations for alleged cognitive disability in the case service plan. The trial court’s service plan directed father to complete a psychological evaluation, maintain contact with caseworkers, and regularly visit MSS. Case workers repeatedly suspected that father had a cognitive disability, although [he] never fully specified the nature of that disability.” Indeed, he “stated he was not diagnosed with a mental impairment and did not take ‘mental health medication.’” The father’s “counsel likewise claimed there were no allegations to justify ordering a psychological evaluation. The trial court also stated it would appoint a guardian ad litem for [him] at his counsel’s request, but there is no evidence a guardian was ever appointed. MSS was in DHHS’s care for over three years, yet father did not complete a psychological evaluation before the adjudication.” According to B, who was then MSS’s caseworker, “he continually changed his phone number, preventing her from contacting him to schedule visits. Father also did not attend multiple scheduled visits while he lived in Michigan in 2024.” As to therapy and parenting classes, he “was terminated from those services in [6/22] because he did not want to participate.” The DHHS referred respondent “for specialized parenting classes to accommodate his suspected disability.” But he did “not attend all of those classes and did not complete the classes before the adjudication.” He also did “not identify what specialized services would have accommodated his alleged disability, nor how he would have benefited from them.” The record showed the “father did not complete or benefit from the services [the DHHS] offered, even the services intended to discern and accommodate his suspected but unconfirmed mental disability.”